State v. Salazar (1995)

In State v. Salazar, 182 Ariz. 604, 898 P.2d 982 (Ariz. Ct. App. 1995), the trial court granted a motion in limine prohibiting the defense from impeaching two of the principal witnesses against the defendant with their juvenile records. The appellate court held that grant of the motion in limine was an abuse of discretion, that the circumstances of the juvenile convictions and the presence of those two witnesses at the scene of the crime inclined them to testify favorably for the state in hopes of avoiding proceedings to revoke their probation, and that the error in disallowing the evidence in dispute could not be considered harmless because it was so central to the defense's theory of its case.